It is also for use by our staff to ensure they apply any sanctions in a consistent manner.

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1 Sanctions Policy Introduction This policy is aimed at Centres delivering BCS approved qualifications or units and who have failed to meet aspects of our delivery requirements and/or the standards laid down by the regulatory authorities in respect of regulated qualifications and units. It sets out the sanctions BCS may impose on Centres in such situations. It is also for use by our staff to ensure they apply any sanctions in a consistent manner. Centre s responsibility It s important that your staff involved in the delivery of our qualifications are fully aware of the contents of the policy and its possible implications on your Centre should you fail to comply with requirements specified by BCS in relation to the delivery of our qualifications (some of which are required of us by the regulators). Review arrangements We ll review the policy annually as part of our self-evaluation arrangements and revise it as and when necessary in response to customer feedback, trends from our internal monitoring arrangements, changes in our practices, actions from the regulatory authorities or external agencies or changes in legislation. If you would like to feedback any views please contact us. Ensuring the standards of our qualifications and units BCS has a responsibility to the learners taking our qualifications and the UK regulatory authorities to ensure that Centres deliver our qualifications and units in accordance with relevant national standards. In order to meet this responsibility the performance of each BCS centre is monitored and verified by our team of experienced Consultants. Page 1 of 6

2 We allocate Consultants to Centres depending on their area of expertise and geographical location and in doing so ensure that Consultants will not be allocated to a Centre at which they have had or have a personal interest. In addition to helping the Centre successfully deliver our qualifications and units and providing them with effective and informed on-going information, advice and guidance in relation to developments with BCS and the wider education and funding systems, the Consultants are responsible for ensuring that each Centre has appropriate quality assurance systems in place. The Consultants will normally assure the quality of delivery by engaging with and working in partnership to monitor the performance of the Centre. The purposes of which are to: address any queries the Centre may have provide the Centre with up-to-date information and advice in line with BCS awards and regulatory authority guidance and requirements review various arrangements at the Centre in accordance with a tailored visit plan for the Centre. For example: o ensuring the Centre is taking all reasonable steps to prevent the occurrence of malpractice or maladministration o confirming that previously identified action points have been met o confirming that assessments are conducted by appropriately qualified and occupationally competent assessors o confirming all learners undertake an initial assessment in order to identify barriers to assessment, exemptions and/or recognition of prior learning (RPL) o checking that assessment decisions are regularly sampled, through internal verification, for accuracy against the national standards o checking that claims for certification are authentic, valid and supported by auditable records and that learners have met the specified level of attainment o ensuring the Centre are retaining appropriate records of assessment and internal verification decisions for three years o ensuring the centre is meeting requirements for learner data retention as set out in our guidance materials to Centres o providing advice and support on the interpretation of national standards, learning outcomes and assessment criteria After the visit the Consultant will produce a report that will be provided electronically to the Centre which will: record the date of the visit highlight areas of good practice detail actions the Centre must take if its performance does not meet our requirements, when these actions must be completed and who is responsible for completing them Page 2 of 6

3 if applicable, and only if serious weaknesses are found, detail any sanctions that will be imposed, or will be recommended to managers within BCS to impose with a rationale for such a decision (see the next section for details) Upon receiving the report the Centre will have the opportunity to review its factual accuracy and will be encouraged to provide feedback on the: conduct of the Consultant findings and outcomes of the visit (if the Centre disagrees with any of the findings and the matter cannot be resolved with the Consultant then they have the opportunity to raise the matter with BCS through the arrangements outlined in our Enquiries and Appeals policy) services and/or support offered by BCS Remote sampling Where assessment marking is conducted at the Centre, BCS will sample and review this activity. This is carried out in addition to the actions carried out during a review visit to ensure the quality of our qualifications and units. The purpose of remote sampling is to: ensuring, through appropriate sampling/moderation, that assessment arrangements are fit for purpose and the criteria against which learners performance is differentiated are being applied consistently by assessors within and across Centres and in accordance with requirements specified for each qualification sampling assessment decisions to confirm that the learner evidence is authentic and valid and that national standards are being consistently maintained and regulatory requirements adhered to If required, the Centre will receive feedback on the quality and consistency of its assessment process and the effectiveness of internal verification/quality assurance arrangements Approach to sanctions BCS has a range of sanctions that can be imposed on a Centre depending on the seriousness of the situation, the level and track-record of the Centre s non-compliance and the risk to the interests of learners and the integrity of the qualifications and units and/or affects the public confidence in BCS qualifications. Nonetheless BCS aims to ensure that the application of sanctions is a last resort and through our approach to Centre support and management, and the creation of appropriate action plans, we will work with Centres to prevent situations arising that would warrant a sanction being imposed. Page 3 of 6

4 However, if sanctions are required then they will be applied depending on the nature of the situation. For example if the Centre has 1 : outstanding actions poor records to confirm assessment decisions no lead quality officer/internal verifier in place proven collusion or persistent bad marking of Centre marked assessments suspected or proven cases of maladministration/malpractice which are being investigated made certification claims before learners have completed the unit(s)/qualification(s) an increased likelihood of an adverse effect occurring (eg something that is likely to have an adverse effect on the standards of the qualifications they are delivering or public confidence in qualifications) refused access to premises and/or records to the staff of BCS or the regulatory authorities cancelled a planned audit without legitimate reason It is important to note that the following are not classified as sanctions, but standard good awarding organisation or business practice: When a Centre is first recognised and approved by us to offer one of our qualifications, and/or if they have subsequently applied and been approved to offer another qualification in a sector or qualification type that is significantly different from previous qualifications they offer, we may approve the Centre to offer the qualification(s) and not process any certificate claims for the qualification(s) until the Centre has received a satisfactory Consultant visit. This approach is normal practice amongst awarding organisations and is generally seen as good practice and is intended to help ensure the Centre is delivering this new qualification effectively before certificates can be issued. Should a Centre refuse to pay outstanding fees after contact with our Finance team, then we may remove approval and/or Centre recognition with immediate effect. Such a decision would not be considered a sanction but a commercial decision. Sanctions that may be imposed Sanctions cannot be imposed directly by the Consultant following the identification of noncompliance. The Consultant will document his/her findings within the Centre assessment report and forward the report to BCS Service Delivery. Non-compliant events will be reviewed by the Service Delivery Manager who is responsible for overseeing the work of the Consultants and for ensuring the appropriateness and consistency of 1 The examples for recommending and imposing sanctions in this section and below are only indicative and are not meant to form an exhaustive list. Page 4 of 6

5 their work, to ensure there is clear evidence of non-compliance by the Centre and/or a sufficient rationale for sanctions to be imposed. The sanction of withholding certificates (eg suspending certification status) can be imposed by the Service Delivery Manager in relation to: all qualifications The sanction in relation to preventing further learner registrations by the centre (eg suspending registration status) can be imposed by the Service Delivery Manager in relation to: all qualifications The sanction in relation to preventing learner testing at the centre can be imposed by the Service Delivery Manager in relation to: all qualifications In the exceptional circumstances of extremely serious non-compliance or the persistent failure of the Centre to address outstanding actions, and/or the failure of previous sanctions to address the issue, BCS would impose, via the Service Delivery Manager the ultimate sanction of removal of qualification approval in relation to: all qualifications and in turn the Centre s recognition with BCS Page 5 of 6

6 BCS expects that it would never impose the immediate withdrawal of approval for a qualification or range of qualifications without: the Centre being given an opportunity to address the area(s) of non-compliance first of all imposing one of the previous sets of sanctions there being evidence that the non-compliance poses a significant threat to the interest of learners or the integrity of the qualifications and units Should a Centre have its approval for a qualification/suite of qualifications removed, we will take all reasonable steps to protect the interests of any learners currently registered for the qualification(s) in line with the details outlined in our Withdrawal of a Qualification process. For example, we will either certificate them for any achievements attained to date and/or seek to transfer them where possible and feasible to another Centre to enable them to carry on with their learning. In all instances the nature of the sanction and the rational for its application will be communicated in writing to the Centre from the Service Delivery Manager. If a Centre disagrees with the imposed sanctions the Centre can make a complaint (in accordance with our Complaints Policy) or appeal (in accordance with our Appeals Policy). Page 6 of 6